VA Appraisal Comps: How Comparable Sales Are Chosen
VA Appraisal Comps: How Comparable Sales Are Chosen
VA appraisal comps are verified closed sales selected for similarity to the home being valued. Appraisers consider location, size, condition, features, concessions and current market conditions, then reconcile adjusted sale prices into an opinion of value. The VA does not impose a fixed one-mile comp radius. Recent sales are preferred, but older or more distant sales can be justified in thin markets. Buyers may provide factual comparable-sale evidence through appropriate channels. [1]
Educational guide · Not a loan approval, appraisal or legal determination
Start With the Answer You Need
Choose a topic to go directly to its rules, real-world examples, and next steps.
Comp Rules
What makes a sale comparable.
Adjustments
Worked sales comparison grid.
Sparse Markets
Older and farther sales explained.
New Builds
Builder incentives and non-disclosure.
Three Windows
Before appraisal, Tidewater and ROV.
Closing Decisions
Value gaps, repairs and buyer choices.
Quick Answers
Common comp and value questions.
VA program permission is not lender approval. Confirm the lender’s exact underwriting, documentation and closing conditions before depending on an estimated amount or timeline.
How VA Appraisers Select Comparable Sales
VA appraisers compare the subject property with reasonably similar closed sales that would compete for the same buyers. Recency matters, but proximity, condition, utility, market segment and reliable adjustments matter more than a simple one-mile circle.
Location and Market Area
Sales within the same subdivision, condominium development or established market are usually strongest when they share the subject’s physical characteristics and likely buyer pool. The handbook says comps should be chosen for similarity, not for a target sale price. [1]
A lower-priced house across a school boundary is not automatically a bad comparable, but the appraiser should evaluate differences that materially affect buyer choices.
Recent Verified Closed Sales
The 2026 handbook prefers closed sales from the most recent six months and generally sales no more than 12 months old unless adequately explained. A current listing, pending sale or price reduction can inform trends but does not replace verified closed-sale evidence.
Thin rural markets can justify older data with clear analysis. [1]
Similar Physical Features
Appraisers examine living area, condition, quality, bedroom/bath utility, lot, garage, age, renovations and unusual features. One nearby home of a very different property type may require more adjustments than a sale farther away.
A large nominal square-footage difference can be acceptable when the market evidence supports the comparison and its adjustment.
Value, Not Asking Price
A seller’s contract price is not proof of VA reasonable value. The appraiser reconciles supported adjusted sale indicators and other relevant approaches. The goal is a credible market-based opinion, not the arithmetic mean of three prices.
Property acceptance also depends on VA condition requirements separately from valuation.
Does VA Require Comps Within One Mile?
No. VA’s current appraisal-report guidance does not impose a fixed minimum or maximum distance between a home and comparable sales. For acreage, rural homes or unusual properties, credible comparable sales may lie many miles away. The report should explain the expanded search and the resulting differences. Likewise, there is no federal rule saying a comp is invalid on the day it passes six months old; more recent and relevant sales are preferred. [1]
| Factor | Strong evidence | Question to ask |
|---|---|---|
| Closed date | Recent verified closing | Is an older sale justified by limited data? |
| Location | Competing neighborhood / market segment | What market differences require adjustments? |
| Gross living area | Comparable above-grade utility | Are unfinished rooms or converted garages treated correctly? |
| Condition and upgrades | Comparable effective condition | Are repair costs wrongly treated as contributory value? |
| Concessions | Identified builder or seller incentives | What market effect did the incentive have? |
| Market trend | Supported stable, rising or falling prices | Was a time adjustment considered? |
Buyers can review the broader VA appraisal gap and Tidewater guide for how the value conclusion affects loan-to-value financing. The VA Minimum Property Requirements process is a separate appraisal obligation, not a substitute for comparable-sale analysis. [3] [4]
How VA Appraisal Comp Adjustments Work
VA appraisers adjust comparable sales for market-supported differences, not automatically for the invoice or retail cost of each feature. The indicated values are reconciled into one reasoned opinion, not merely averaged.
Worked Example: Three Sales With Market Adjustments
| Feature | Comp A | Comp B | Comp C |
|---|---|---|---|
| Sold price | $410,000 | $425,000 | $397,000 |
| Size / utility adjustment | +$7,000 | -$4,000 | +$12,000 |
| Condition / features | +$5,000 | +$3,000 | +$6,000 |
| Market-time adjustment | +$2,000 | $0 | +$4,000 |
| Seller concession effect | $0 | -$4,000 | $0 |
| Illustrative adjusted indicator | $424,000 | $420,000 | $419,000 |
Here the adjusted values cluster from $419,000 to $424,000. A defensible reconciled opinion might fall within that range, depending on which sale is most comparable and the quality of its adjustments. This is arithmetic for education, not a rule that three comps must be averaged or a valuation of an actual house. The appraiser must explain market support for major differences and the final reconciliation. [1]
Contributory Value Is Not Renovation Cost
A $30,000 remodel does not automatically add $30,000. The contribution depends on what a typical buyer in the local market pays for the improvement, its age and its functional relevance.
Likewise, the cost of building a swimming pool does not prove equal resale value in every neighborhood.
Seller Concessions Need Market Evidence
VA guidance says concession adjustments should reflect their market effect, not mechanically subtract the entire credit. It also specifies that seller-concession adjustments, when warranted, are downward rather than upward.
A builder rate buydown can matter differently than a modest ordinary closing credit.
Time Adjustments Reflect the Contract Date
The appraiser may analyze price movements between a comparable sale’s contract date and the appraisal’s effective date. Evidence can include repeat sales and market trend analysis, not a nationwide automatic monthly appreciation formula.
Property Condition Is a Separate Review
An appraisal subject to repair completion generally compares the property in the condition expected once required repairs are made. A failing roof may generate an MPR condition, not merely a small value discount.
What If Recent Comparable Sales Are Missing?
A sparse market does not automatically prevent a VA appraisal, but it requires stronger documentation. The VA directs appraisers to use the best available market evidence and explain why conventional nearby sales are not available.
Rural Acreage
A ranch-style home on several acres may compete with properties sold outside the closest subdivision or even outside the immediate county. There is no universal maximum-mile rule; what matters is how buyers compare the properties. [1]
Provide acreage, water source, access, fencing, outbuildings and any legal use distinctions so the appraiser can select the right market segment.
Custom or Unusual Housing
Unique floor plans, mixed-quality additions, large workshops, accessory units or limited-access communities can make every comp imperfect. A well-explained selection and multiple market-derived adjustments may be unavoidable.
Unusual features do not guarantee a premium if there are no buyers paying extra for them.
Declining or Rapidly Changing Market
When closing prices trend downward, a three-month-old sale can overstate current value unless the appraiser evaluates a time adjustment. In a fast-rising market, an older sale may require a supported positive adjustment instead.
Current listings and pendings may help illustrate conditions but are different evidence from verified closings.
Distressed or Nontraditional Sales
REO and short sales may be usable when prevalent in the market, but a foreclosure transfer to a mortgage servicer is not itself a market-value sale. Financing and seller motivations affect how a transaction should be interpreted. [1]
Does a Larger Search Radius Always Lower the Value?
No. A wider search can improve comparability when nearby sales differ materially in size, land or quality. A 14-mile comparable on a similar rural tract may be more probative than a half-mile suburban house. A geographically distant comp should be explained; it should not be rejected solely because a closer, inferior match exists.
Can Active or Pending Listings Fill a Missing Comp Slot?
Pending contracts and current listing activity can help an appraiser evaluate market movement, supply and demand. They generally should not be presented as equivalent to closed sales that establish realized transaction prices. For a Tidewater response, mark each sale’s status clearly and provide confirmation of actual closing when available. [2]
New Construction, Builder Incentives and Texas Non-Disclosure
New subdivisions and Texas resale markets can produce appraisal-data gaps for different reasons. Neither allows an appraiser simply to accept the builder’s contract or a buyer’s unverified price estimate as market value.
How New-Construction VA Appraisal Comps Differ
Appraiser studies plans, specifications, floor plan, site and planned improvements as appropriate.
Seek recent competing-builder sales and existing neighborhood sales where they represent substitutes.
Verify whether advertised closing credits, upgrades or rate buydowns influenced actual sale prices.
Analyze lot position, finish quality, building size and market trends with comparable closing data.
Follow applicable final-inspection and documentation requirements; appraisal is not a full property inspection.
VA Chapter 11 specifically discusses sales from competing developments when a proposed new subdivision has few transactions. A builder’s own recent closings may be useful but should not automatically stand in for all competing market evidence. Subsidized financing and large incentive packages can affect comparability and require careful analysis. [1]
Texas Is a Non-Disclosure State: What Actually Changes?
Texas generally does not require the same public disclosure of sale consideration found in many other states. That means deed records alone may not provide reliable closed prices. Appraisers can use MLS records, verified contracts, closing information and other professionally available sources, subject to access and verification. A buyer’s agent can help assemble closed-sale evidence, but a claimed off-market price without verifiable documentation is weak.
Useful Texas Agent Packet
- Recently closed addresses with reliable sold prices
- MLS printouts where available
- Closed date and gross living area
- Documented builder incentives or seller concessions
- Property photos, lot and upgrade comparisons
- Explanation of which buyers would consider each home
Avoid These Mistakes
- Comparing list prices to closed-sale prices
- Assuming a new build is worth the sum of paid upgrades
- Treating a sale in a different submarket as identical
- Submitting a family member’s unverified transaction
- Assuming public non-disclosure means an appraiser has no data
- Pressuring an appraiser to support the contract price
For a duplex or four-unit property, rental potential can complicate comparability. See the VA multifamily purchase guide for owner-occupancy and income rules, but those rules do not replace a market-supported appraisal of the property.
When to Submit Comps: Before Appraisal, Tidewater and ROV
You may share relevant market information with the lender before appraisal, respond during a Tidewater request before the value is finalized, or ask for a Reconsideration of Value after the Notice of Value. Each step has a different procedural purpose.
| Stage | Who handles it | What matters |
|---|---|---|
| Before report | Agent or borrower gives credible sale data through lender | Avoid assuming the appraiser is required to adopt proposed comps |
| Tidewater | Appraiser contacts designated point of contact/requester before finalizing an apparent shortfall | Requester gets 2 business days to supply additional sales data |
| Reconsideration of Value | Veteran initiates formal review through lender / appropriate VA process after NOV | Identify verifiable data errors and alternative closed sales; revision is not guaranteed |
What Does the Two-Business-Day Tidewater Window Mean?
The VA handbook states that when an appraiser expects the opinion of value may fall below contract price, the requester or parties contacted by the requester have two business days to submit additional sales information before the appraisal is finished. This is not necessarily 48 consecutive hours. The data should include address, sale price, closing date, living area, listing details where available, and why it is comparable. [2]
Select verified closed transactions in the competing market, preferably not already used.
Provide a factual cover note that explains size, condition, time and location differences.
The appraiser must evaluate the evidence; there is no obligation to raise the value.
If the concluded value still differs, the buyer reviews contract options and potential reconsideration.
Can You Contact the VA Appraiser Directly?
Borrowers and agents should normally coordinate through the designated contact or lender, respecting independence requirements. Do not threaten, pressure or promise business to the appraiser for a target result. The aim is to transmit accurate market evidence, not to negotiate an opinion of value. The Tidewater procedure guide and appraisal reconsideration guide give the distinct process and documentation considerations.
What to Do With a Low VA Appraisal or a Weak Comp Set
A low value matters because ordinary VA purchase financing is generally constrained by the lower of the purchase price or appraised value. Decide whether the problem is market evidence, purchase price, or cash availability before escalating.
Worked Example: A $425,000 Contract With a $405,000 Appraisal
| Choice | Illustrative buyer exposure | Tradeoff |
|---|---|---|
| Seller reduces contract to $405,000 | No original $20,000 gap, other costs remain | Seller must agree |
| Buyer pays full $425,000 | $20,000 valuation difference, in addition to other cash needs | Buyer must have documented funds and accept market risk |
| Split difference at $415,000 | $10,000 above appraisal, before other cash | Both sides compromise |
| Seek ROV supported by new data | Amount depends on any changed NOV | Value may remain unchanged |
| Use applicable VA escape clause | May allow buyer to avoid obligation to complete above VA-established value | Contract rights and proper clause wording matter |
This example assumes sufficient entitlement, a full-value purchase analysis and no special lender down-payment overlay. If the price remains $425,000 and value is $405,000, the $20,000 gap is not automatically included in the base purchase mortgage. Confirm closing-cost, earnest-money and contract remedies with the lender and real estate professionals. [3]
VA Appraisal Is Not a Home Inspection
The appraiser provides a value opinion and evaluates visible minimum property requirements. A buyer should still obtain an independent inspection for systems, foundation, water intrusion and hazards. The 2026 MPR revision does not make unsafe property automatically acceptable. [4]
Appraisal Fees Are Not Funding Fees
VA appraisal charges are separate from the VA funding fee. Appraisal fees may follow regional allowable schedules; the VA funding fee depends on loan type, use, down payment and exemption status. Compare all charges in the closing costs. [6]
Checklist for Reviewing a Potentially Weak Appraisal
- Confirm every comp actually closed and matches the sales data shown.
- Check whether comparables represent the same housing type and relevant location.
- Review square footage, room-count, finished-area and condition descriptions.
- Look for documented time, concession and renovation adjustments.
- Identify specific factual errors rather than objections to the result alone.
- Give the lender the best additional closed sales and a short reasoned explanation.
- Revisit your appraisal contingency and VA escape-clause rights before deadlines expire.
If you submit confidential borrower details through a VALN request, review the privacy policy and terms of use before providing personal information. For broader purchase eligibility, see the VA home loan overview and Certificate of Eligibility guide.
Frequently Asked Questions
Direct answers to common search questions and special-case scenarios.
How many comps does a VA appraisal require?
VA appraisals ordinarily use at least three closed comparable transactions to analyze market value. The quality of the sales, explanatory adjustments and final reconciliation matter as much as the count. [1]
Do VA appraisal comps have to be within one mile?
No. The VA does not prescribe a minimum or maximum comparable-sale distance. The appraiser must explain why distant sales best represent the subject market. [1]
How old can VA appraisal comps be?
Sales within six months are preferred, and sales generally should not exceed 12 months without an explanation. Older relevant sales may be used when the market has limited activity. [1]
Can a VA appraiser use comps from another school district?
Yes, when those properties compete for similar buyers and any market differences are analyzed. The school boundary itself does not establish an automatic federal prohibition.
Does a VA appraisal use the average of three sold prices?
No. VA appraisers reconcile adjusted evidence. The most comparable transactions may receive greater weight than weaker matches, and the appraiser must support the value opinion. [1]
Are pending sales accepted as VA comps?
Pending sales and active listings can help inform market conditions but should not be conflated with verified closed sales that establish realized prices.
Can seller credits reduce a VA appraised value?
Potentially. Appraisers evaluate a concession’s market effect. VA guidance does not require a mechanical dollar-for-dollar reduction for every credit; an adjustment must be market-derived. [1]
How are VA appraisal comps chosen for new construction?
Appraisers look for similar completed transactions, including other builders and competing developments when available, and consider plans, features and builder concessions. There is no automatic builder-price acceptance. [1]
Does Texas non-disclosure prevent a VA appraisal?
No. Texas makes closed prices less accessible through public records, but MLS information and other properly verified data sources may support appraisal analysis.
What if there are no comparable sales near the home?
The appraiser can broaden the search, consider older sales and explain the limitations. The report still needs a supportable market-value conclusion. [1]
What does Tidewater mean on a VA appraisal?
It is the pre-report process used when the appraiser expects a value below contract price. The requester has two business days to submit additional sales data. It does not guarantee a higher result. [2]
Can I appeal a completed VA appraisal?
A Veteran may pursue a Reconsideration of Value after the Notice of Value using verifiable new sales data or documented factual errors. The lender and appropriate VA review process coordinate the request; a change is not automatic. [3]
Do VA appraisers have to accept comps from my agent?
No. A buyer’s agent can submit reliable closed sales through the appropriate process, but the independent appraiser evaluates whether they are meaningful market indicators.
Does a VA appraisal check for structural and safety problems?
Yes, the VA appraisal includes MPR review, but is not a substitute for a professional home inspection. Applicable VA standards were updated in 2026. [4]
What happens if the VA appraisal is $20,000 low?
The buyer may negotiate the price, consider a supported value review, add documented funds for a gap or use applicable contract and escape-clause protections. The gap is not automatically financed. [3]
Is a VA appraisal fee the same as the VA funding fee?
No. The appraisal fee pays for valuation services. The funding fee is a distinct VA program charge that depends on loan type, use and qualifying exemptions. [6]
Sources and Verification
Federal VA, CFPB, FHFA and HUD materials checked November 6, 2026. Individual lenders may impose narrower policies.
Find a VA Lender That Can Review Your Specific File.
Compare written loan terms, ask about any lender-specific restrictions, and confirm the documentation needed before you commit.